News & Analysis as of

Department of Justice (DOJ) Internal Revenue Code (IRC) Income Taxes

Fox Rothschild LLP

DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales

Fox Rothschild LLP on

An installment sale occurs when property is disposed of and at least one payment is received after the tax year of the disposition. See I.R.C. § 453. Under a standard installment sale, the buyer makes scheduled payments to...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

McDermott Will & Emery

Can the Government Sue for Tax Debts Outside IRC Procedures?

McDermott Will & Emery on

On June 1, 2023, in United States v. Liberty Global, Inc.[1], the US District Court for the District of Colorado held that the US Department of Justice (DOJ) can assert and seek judgment for federal income tax deficiencies...more

Miller Canfield

High-Profile Case Highlights Government's Common Law Right to Pursue Tax Deficiencies in Court

Miller Canfield on

A federal district court ruled in a high-profile case that the Justice Department may rely on common law rather than the statutory notice of tax deficiency procedure in the Internal Revenue Code to assert a federal income tax...more

Morgan Lewis

Successful Oil Excise Tax Challenge Leads to Opportunities and Uncertainty for Exporters

Morgan Lewis on

A recent challenge to the constitutionality of the federal excise tax on domestic crude oil exported from the United States proved successful in the US Court of Appeals for the Fifth Circuit. While the US Department of...more

Oberheiden P.C.

What Tax Preparers Need to Know Before Sitting for an IRS CI Interview

Oberheiden P.C. on

The Internal Revenue Service’s Criminal Investigation Division (IRS CI) is targeting tax preparers or the ones who prepare tax returns in 2022. IRS CI is focusing its efforts on tax preparers who underreport their clients’...more

Freeman Law

DOJ-Tax Alleges President of We Build the Wall Filed a False Tax Return and Committed Wire Fraud

Freeman Law on

Taxpayers who file false tax returns with the IRS can find themselves in hot water.  Indeed, section 7206(1) of the Internal Revenue Code (“Title 26”) makes it a felony to file a false return when the taxpayer knows that the...more

Jones Day

New Appellate Court Ruling on Priority of Straddle-Year Taxes in Bankruptcy

Jones Day on

A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than...more

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